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49 CFR 393.11, Footnote 11 - Inoperable Licence Plate Lights

Entry DateJanuary 17, 2013
Issue Number13-002-VEH
NameJerry Keifer
AgencyMercer Transportation Co, Inc.
Address1128 West Main StreetLouisville, KY, 40203United StatesMap It (opens in a new tab)
Phone502-625-3168
Fax(502) 325-3158
Email[email protected]
CommitteeVehicle Committee
StatusClosed
Summary of Issue

I am requesting a "Request for Action" concerning the citing of inoperable license plate lamps on the rear of truck tractors registered in states not requiring a rear license plate on the truck tractor. A request has been submitted by me to FMCSA to add wording to 393.11, Footnote 11 to read "Lamp is not required to be operable when on a truck tractor registered in a state that does NOT require a rear license plate". I have reviewed numerous inspections for the carrier listed above and other carriers where the only vehicle violation cited is for the license plate lamp and the points accessed under CSA are the same as for a headlamp, turn or stop lamp inoperable.

Justification or Need

The citing of the this violation on the MCSAP reports adds points unnecessarily to a carrier CSA maintenance basic when this lamp serves no function when a license plate is not required by the registration state.

Request for Action

I would ask that CVSA issue an advisory requesting that inspectors not cite the carrier for a inoperable license plate lamp when a license plate is not required to be displayed on the rear of the truck tractor.